Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Addition for unexplained expenditure on alleged bogus purchases was deleted because the books of account were not rejected and there was no tangible material showing that the purchases were inflated, bogus or otherwise unexplained. The assessee had produced primary records, including books, stock and purchase registers, bank statements, import documents and supplier ledgers, and the department did not discredit the quantitative or banking evidence; an ad hoc percentage disallowance could not replace proof. On the TDS mismatch issue arising from Form 26AS discrepancies, the direction to verify the assessee's claim of revised TDS returns and delete the addition if supported was upheld.
Addition for unexplained expenditure on alleged bogus purchases was deleted because the books of account were not rejected and there was no tangible material showing that the purchases were inflated, bogus or otherwise unexplained. The assessee had produced primary records, including books, stock and purchase registers, bank statements, import documents and supplier ledgers, and the department did not discredit the quantitative or banking evidence; an ad hoc percentage disallowance could not replace proof. On the TDS mismatch issue arising from Form 26AS discrepancies, the direction to verify the assessee's claim of revised TDS returns and delete the addition if supported was upheld.
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